The document summarizes changes to estate laws in 2011 and 2012. Key points include:
- The federal estate tax exemption was $5 million in 2011 and increased to $5.12 million in 2012. Tennessee's exemption remained at $1 million.
- The federal estate and gift tax rate was 35% in 2011-2012. Tennessee's maximum rate is 9.5%.
- Portability between spouses was extended, allowing married couples to shield up to $10 million from federal estate taxes. Tennessee does not recognize portability.
- Other changes included the gift tax annual exclusion amount and generation-skipping tax exemption and rates.
The Tax Cuts and Jobs Act has now passed, which enacts the biggest tax reform law in thirty years. Citrin Cooperman's Federal Tax Policy Team recently hosted a webinar discussing what you need to know to begin planning and steps you can be taking to be prepared. The conversation focused on the following key areas:
Business
Corporate
Pass-Through Entities
International
Individuals
State and Local Implications
The passage of the Tax Cuts and Jobs Act will have widespread and long lasting implications throughout the country and will change how most taxpayers will prepare their tax returns. Citrin Cooperman recently hosted a seminar in Philadelphia to provide insight on where we are now, how we plan to move forward, and how the new law will impact your overall business and tax strategies. Join us to get answers to questions in the following areas:
Corporate and Businesses
Pass-Through Entities
International Issues
Individuals
The Long Lasting Impact of Tax Reform- NYC- Event- 1/24/18Citrin Cooperman
The passage of the Tax Cuts and Jobs Act will have widespread and long lasting implications throughout the country and will change how most taxpayers will prepare their tax returns. Citrin Cooperman recently hosted a seminar in NYC to provide insight on where we are now, how we plan to move forward, and how the new law will impact your overall business and tax strategies.
Speeding Through 2020 Auto Webinar Series - Year-End ReviewCitrin Cooperman
As 2020 nears completion, we discuss what automotive dealerships need to record and what files need to be kept in order to ensure that 2020 is closed properly and that the new year starts off right.
High Net Worth Webinar Series: SALT Thoughts - Pass-Through Entity Taxes & Re...Citrin Cooperman
During this webinar, we discussed how to potentially mitigate the impact of the state and local tax (SALT) cap at the federal level. New York State has joined the list of states that have enacted an elective pass-through entity tax in an effort to do just that. We also dove into the possibility of changing residency to a low-tax or no-tax state. With state tax rates on the rise in some places and the realization that remote work is doable, many individuals are contemplating making a move. To succeed in making a change like this, one must be aware of the technical rules and be willing to significantly adjust one’s life. We talked through all these considerations.
The Tax Cuts and Jobs Act has now passed, which enacts the biggest tax reform law in thirty years. Citrin Cooperman's Federal Tax Policy Team recently hosted a webinar discussing what you need to know to begin planning and steps you can be taking to be prepared. The conversation focused on the following key areas:
Business
Corporate
Pass-Through Entities
International
Individuals
State and Local Implications
The passage of the Tax Cuts and Jobs Act will have widespread and long lasting implications throughout the country and will change how most taxpayers will prepare their tax returns. Citrin Cooperman recently hosted a seminar in Philadelphia to provide insight on where we are now, how we plan to move forward, and how the new law will impact your overall business and tax strategies. Join us to get answers to questions in the following areas:
Corporate and Businesses
Pass-Through Entities
International Issues
Individuals
The Long Lasting Impact of Tax Reform- NYC- Event- 1/24/18Citrin Cooperman
The passage of the Tax Cuts and Jobs Act will have widespread and long lasting implications throughout the country and will change how most taxpayers will prepare their tax returns. Citrin Cooperman recently hosted a seminar in NYC to provide insight on where we are now, how we plan to move forward, and how the new law will impact your overall business and tax strategies.
Speeding Through 2020 Auto Webinar Series - Year-End ReviewCitrin Cooperman
As 2020 nears completion, we discuss what automotive dealerships need to record and what files need to be kept in order to ensure that 2020 is closed properly and that the new year starts off right.
High Net Worth Webinar Series: SALT Thoughts - Pass-Through Entity Taxes & Re...Citrin Cooperman
During this webinar, we discussed how to potentially mitigate the impact of the state and local tax (SALT) cap at the federal level. New York State has joined the list of states that have enacted an elective pass-through entity tax in an effort to do just that. We also dove into the possibility of changing residency to a low-tax or no-tax state. With state tax rates on the rise in some places and the realization that remote work is doable, many individuals are contemplating making a move. To succeed in making a change like this, one must be aware of the technical rules and be willing to significantly adjust one’s life. We talked through all these considerations.
C-Suite Snacks Webinar Series: There’s No Vaccine for This - State and Local ...Citrin Cooperman
Sign up for our weekly C-Suite Snacks webinars here: https://www.citrincooperman.com/infocus/c-suite-snacks
Our C-Suite Snacks webinar series provides the middle market with brief, strategic, and tactical business improvement information for 30 minutes every week. Join Citrin Cooperman live every Thursday at noon for snack-sized insights for business executives.
The pandemic has affected everything in our lives, all the way down to how we run our businesses and our personal finances. In this session, State and Local Tax Partner Eugene Ruvere covered business and personal income tax considerations connected to the pandemic.
The New Rage in SALT: State Pass-Through Entity TaxCitrin Cooperman
During this webinar, Partner Eugene Ruvere and Principal Jaime Reichardt take deeper dive into the new elective tax regime in New York, in addition to neighboring states like Connecticut, New Jersey, and Rhode Island, among others.
Presenters:
• Chuck Miller, CEO, NgenX Energy
• Martin Harski, Cost Segregation Principal, National Tax Service Group, Withum
• Cary Milstein, Early Entrepreneur, Medical Cannabis Sector
After a year of uncertainty and economic disruption, the restaurant industry has won federal relief. On March 11 President Biden signed the American Rescue Plan into law which includes a $28.6 billion Restaurant Revitalization Fund (RRF) to assist struggling restaurants during the pandemic. The RRF impacts restaurant owners with 20 or fewer locations and will be administered by the Small Business Administration.
Topics for discussion:
- Who is eligible for RRF?
- How can the fund be used?
- Next steps and important considerations for restaurant owners
2021 Year End Tax Planning for Law Firms and AttorneysWithum
2021 has ushered in a return to what we can consider our new normal for the foreseeable future. The impact of COVID-19 on law firms persists in the form of hybrid work environments as managing partners are tasked with creating return-to-work policies with flexible remote work options.
With remote work comes complicated nexus implications that law firms must navigate. Meanwhile, federal and state tax laws, particularly Pass-Through Entity Taxes (PTET), continue to impact law firms in a unique way.
2020 Year-End Tax Planning for Law Firms and AttorneysWithum
Tax planning can be a difficult strategic process; this tax planning season is further complicated by the COVID-19 pandemic as well as the uncertainties surrounding the Presidential Election. This session will shed light on a number of significant considerations regarding NJ BAIT, nexus issues related to remote working, and PPP loan forgiveness as it relates to general high net worth planning.
International tax reporting requirements relevant to U.S. persons engaged in cross-border transactions. Foreign information returns discussed include Forms 926, 5471, 5472, 8858, and 8865. The discussion focuses upon proper execution of the Forms and potential penalties for noncompliance.
View the video recording here: https://youtu.be/UyNXjUoFxYA
Learn more about Citrin Cooperman's International Tax Services here: http://bit.ly/2veYkrO
The need to promote mental health and tackle sigma made us take the stage at a local health fair. The day was shared amongst people who use mental health services and those who work alongside them.
C-Suite Snacks Webinar Series: There’s No Vaccine for This - State and Local ...Citrin Cooperman
Sign up for our weekly C-Suite Snacks webinars here: https://www.citrincooperman.com/infocus/c-suite-snacks
Our C-Suite Snacks webinar series provides the middle market with brief, strategic, and tactical business improvement information for 30 minutes every week. Join Citrin Cooperman live every Thursday at noon for snack-sized insights for business executives.
The pandemic has affected everything in our lives, all the way down to how we run our businesses and our personal finances. In this session, State and Local Tax Partner Eugene Ruvere covered business and personal income tax considerations connected to the pandemic.
The New Rage in SALT: State Pass-Through Entity TaxCitrin Cooperman
During this webinar, Partner Eugene Ruvere and Principal Jaime Reichardt take deeper dive into the new elective tax regime in New York, in addition to neighboring states like Connecticut, New Jersey, and Rhode Island, among others.
Presenters:
• Chuck Miller, CEO, NgenX Energy
• Martin Harski, Cost Segregation Principal, National Tax Service Group, Withum
• Cary Milstein, Early Entrepreneur, Medical Cannabis Sector
After a year of uncertainty and economic disruption, the restaurant industry has won federal relief. On March 11 President Biden signed the American Rescue Plan into law which includes a $28.6 billion Restaurant Revitalization Fund (RRF) to assist struggling restaurants during the pandemic. The RRF impacts restaurant owners with 20 or fewer locations and will be administered by the Small Business Administration.
Topics for discussion:
- Who is eligible for RRF?
- How can the fund be used?
- Next steps and important considerations for restaurant owners
2021 Year End Tax Planning for Law Firms and AttorneysWithum
2021 has ushered in a return to what we can consider our new normal for the foreseeable future. The impact of COVID-19 on law firms persists in the form of hybrid work environments as managing partners are tasked with creating return-to-work policies with flexible remote work options.
With remote work comes complicated nexus implications that law firms must navigate. Meanwhile, federal and state tax laws, particularly Pass-Through Entity Taxes (PTET), continue to impact law firms in a unique way.
2020 Year-End Tax Planning for Law Firms and AttorneysWithum
Tax planning can be a difficult strategic process; this tax planning season is further complicated by the COVID-19 pandemic as well as the uncertainties surrounding the Presidential Election. This session will shed light on a number of significant considerations regarding NJ BAIT, nexus issues related to remote working, and PPP loan forgiveness as it relates to general high net worth planning.
International tax reporting requirements relevant to U.S. persons engaged in cross-border transactions. Foreign information returns discussed include Forms 926, 5471, 5472, 8858, and 8865. The discussion focuses upon proper execution of the Forms and potential penalties for noncompliance.
View the video recording here: https://youtu.be/UyNXjUoFxYA
Learn more about Citrin Cooperman's International Tax Services here: http://bit.ly/2veYkrO
The need to promote mental health and tackle sigma made us take the stage at a local health fair. The day was shared amongst people who use mental health services and those who work alongside them.
Alyvix: Synthetic Monitoring @ Icinga Camp Berlin 2017Julia Helfer
Alyvix is a synthetic monitoring system based on computer vision, that automates interactions with application GUIs, exactly as a human user would do and measures the perceived performance. At the Icinga Camp Berlin 2017, Francesco Melchiori presented the open source tool and it's integration to Icinga 2.
The second talk in the 2017 50k Training program presented by Charlottesville Area Trail Runners and Crozet Running.
Kristen Chang shares her knowledge and experience as a registered dietitian and endurance athlete. She discusses how to fuel, hydrate, and nourish your body during training and racing, and answer questions about the pros and cons of different nutrition strategies.
Kristen's website: http://www.realfoodforfuel.com/about-kristen.html
2018 Pennsylvania Tax Update: The State Budget, Legislation, and Multistate T...McKonly & Asbury, LLP
This webinar was hosted by McKonly & Asbury Senior Tax Manager and SALT Leader, Michael Eby, and Tax Supervisor, Lindsey Waltemyer.
It provides an overview of the enacted 2017-2018 Pennsylvania State Budget; a brief update on recently passed Pennsylvania tax legislation and court decisions of interest; and discusses how states, including Pennsylvania, are addressing these changes at the Federal level in their own respective tax structure.
Tax Cuts and Jobs Act: Individual Tax Planning InsightRea & Associates
The new Tax Cuts and Jobs Act managed to pack in a lot of changes for individual filers, many of which have left more than a few of us scratching our heads. This webinar will dive into the provisions that will have the most impact on individual tax strategy, including changes associates with trusts and estates. Cindy Kula, CPA, PFS, CFP, and Inez Bowie, CPA, CSEP, have already spent countless hours combing through the legislation and additional guidance so you don’t have to. Join us for this session to find out what they found.
California Incentives and Multi-State Tax Issues webinar slidesRoger Royse
An online discussion of various state tax issues for companies and individuals doing business in California. Our panelists cover recent developments in California income and sales tax, tax credits and incentives, multi-state tax issues for technology companies and state residency planning for individuals. Our panel of speakers includes:
Roger Royse, Royse Law Firm
Monika Miles, Miles Consulting Group
David Wittrock, Price, Wittrock CPA LLP
David Spence, Royse Law Firm
Property Tax Basics and Related Incentives by Tushar Chikhliker, South Caroli...Nexsen Pruet
Burnie Maybank hosted the Nexsen Pruet Newbie Seminar on December 1, 2011. The Newbie Seminar is designed for those new to the economic development field in South Carolina or those who would like some brushing up. Covered topics included basic property, sales and income taxes, as well as Bonds, the utility tax credit and FOIA.
This presentation contains the public finance portion of the seminar presented by Nexsen Pruet economic development attorney Tushar Chikhliker.
Smith Haughey Rice & Roegge presents the latest in property taxes for 2014. Smithhaughey
A seminar that walks you through taxes 101, personal property taxes, exempt property, recent developments in real property taxation, real estate tax issues for seniors and veterans, planning opportunities and pitfalls.
Income Tax Tips for PFMs Working with Military Familiesmilfamln
This is a free webinar hosted by the Personal Finance concentration area of the Military Families Learning Network.
This 90-minute webinar will address updates to tax changes that affect military families and service members. Barbara O’Neill will discuss tax basics and common tax errors during the first half hour of this interactive webinar. In the second half Taylor Spangler of University of Florida Extension will talk about the specific tax issues of concern to military families, as well as provide military specific resources for tax help and support. Carol Kando-Pineda of the Federal Trade Commission will close the session with an update on the resources available through identitytheft.gov. Find more info: https://learn.extension.org/events/3191
2014 wla conference big tax ideas that save real moneyDebby Keegan
This presentation highlights the top 5 tax things you need to know for 2014 if you're in the lodging industry. This high level discussion means you can leave your slide rule and pocket protectors at home! We will focus on how you can put real money back into your pockets.
Forensics and Fraud: Red Flags and War StoriesDecosimoCPAs
Principal Mike Costello, CPA•ABV•CFF, ASA, CFE, Director of Litigation Support Sharon P. Hamrick, CPA•CFF, CFE and Senior Manager Pamela S. Mantone, CPA•CFF, CFE, FCPA, CITP, CGMA co-presented the topic "Forensics and Fraud: Red Flags and War Stories" at the 2013 TSCPA FSV Conference, during which they shared from their experiences the details of various fraud schemes and methods used to detect and investigate them. - See more at: http://decosimo.com/www/announcements/540.8136/forensic-accounting-fraud-specialists-share-expertise-tscpa#sthash.eEdR6hfE.dpuf
Assurance Principal Jennifer Goodman presented "What Was the FASB Thinking?," a discussion and examples of unusual accounting rules, at the 2013 Decosimo Accounting Forum hosted by the University of North Alabama on July 19.
LF Energy Webinar: Electrical Grid Modelling and Simulation Through PowSyBl -...DanBrown980551
Do you want to learn how to model and simulate an electrical network from scratch in under an hour?
Then welcome to this PowSyBl workshop, hosted by Rte, the French Transmission System Operator (TSO)!
During the webinar, you will discover the PowSyBl ecosystem as well as handle and study an electrical network through an interactive Python notebook.
PowSyBl is an open source project hosted by LF Energy, which offers a comprehensive set of features for electrical grid modelling and simulation. Among other advanced features, PowSyBl provides:
- A fully editable and extendable library for grid component modelling;
- Visualization tools to display your network;
- Grid simulation tools, such as power flows, security analyses (with or without remedial actions) and sensitivity analyses;
The framework is mostly written in Java, with a Python binding so that Python developers can access PowSyBl functionalities as well.
What you will learn during the webinar:
- For beginners: discover PowSyBl's functionalities through a quick general presentation and the notebook, without needing any expert coding skills;
- For advanced developers: master the skills to efficiently apply PowSyBl functionalities to your real-world scenarios.
UiPath Test Automation using UiPath Test Suite series, part 4DianaGray10
Welcome to UiPath Test Automation using UiPath Test Suite series part 4. In this session, we will cover Test Manager overview along with SAP heatmap.
The UiPath Test Manager overview with SAP heatmap webinar offers a concise yet comprehensive exploration of the role of a Test Manager within SAP environments, coupled with the utilization of heatmaps for effective testing strategies.
Participants will gain insights into the responsibilities, challenges, and best practices associated with test management in SAP projects. Additionally, the webinar delves into the significance of heatmaps as a visual aid for identifying testing priorities, areas of risk, and resource allocation within SAP landscapes. Through this session, attendees can expect to enhance their understanding of test management principles while learning practical approaches to optimize testing processes in SAP environments using heatmap visualization techniques
What will you get from this session?
1. Insights into SAP testing best practices
2. Heatmap utilization for testing
3. Optimization of testing processes
4. Demo
Topics covered:
Execution from the test manager
Orchestrator execution result
Defect reporting
SAP heatmap example with demo
Speaker:
Deepak Rai, Automation Practice Lead, Boundaryless Group and UiPath MVP
Slack (or Teams) Automation for Bonterra Impact Management (fka Social Soluti...Jeffrey Haguewood
Sidekick Solutions uses Bonterra Impact Management (fka Social Solutions Apricot) and automation solutions to integrate data for business workflows.
We believe integration and automation are essential to user experience and the promise of efficient work through technology. Automation is the critical ingredient to realizing that full vision. We develop integration products and services for Bonterra Case Management software to support the deployment of automations for a variety of use cases.
This video focuses on the notifications, alerts, and approval requests using Slack for Bonterra Impact Management. The solutions covered in this webinar can also be deployed for Microsoft Teams.
Interested in deploying notification automations for Bonterra Impact Management? Contact us at sales@sidekicksolutionsllc.com to discuss next steps.
Neuro-symbolic is not enough, we need neuro-*semantic*Frank van Harmelen
Neuro-symbolic (NeSy) AI is on the rise. However, simply machine learning on just any symbolic structure is not sufficient to really harvest the gains of NeSy. These will only be gained when the symbolic structures have an actual semantics. I give an operational definition of semantics as “predictable inference”.
All of this illustrated with link prediction over knowledge graphs, but the argument is general.
The Art of the Pitch: WordPress Relationships and SalesLaura Byrne
Clients don’t know what they don’t know. What web solutions are right for them? How does WordPress come into the picture? How do you make sure you understand scope and timeline? What do you do if sometime changes?
All these questions and more will be explored as we talk about matching clients’ needs with what your agency offers without pulling teeth or pulling your hair out. Practical tips, and strategies for successful relationship building that leads to closing the deal.
Transcript: Selling digital books in 2024: Insights from industry leaders - T...BookNet Canada
The publishing industry has been selling digital audiobooks and ebooks for over a decade and has found its groove. What’s changed? What has stayed the same? Where do we go from here? Join a group of leading sales peers from across the industry for a conversation about the lessons learned since the popularization of digital books, best practices, digital book supply chain management, and more.
Link to video recording: https://bnctechforum.ca/sessions/selling-digital-books-in-2024-insights-from-industry-leaders/
Presented by BookNet Canada on May 28, 2024, with support from the Department of Canadian Heritage.
GraphRAG is All You need? LLM & Knowledge GraphGuy Korland
Guy Korland, CEO and Co-founder of FalkorDB, will review two articles on the integration of language models with knowledge graphs.
1. Unifying Large Language Models and Knowledge Graphs: A Roadmap.
https://arxiv.org/abs/2306.08302
2. Microsoft Research's GraphRAG paper and a review paper on various uses of knowledge graphs:
https://www.microsoft.com/en-us/research/blog/graphrag-unlocking-llm-discovery-on-narrative-private-data/
Essentials of Automations: Optimizing FME Workflows with ParametersSafe Software
Are you looking to streamline your workflows and boost your projects’ efficiency? Do you find yourself searching for ways to add flexibility and control over your FME workflows? If so, you’re in the right place.
Join us for an insightful dive into the world of FME parameters, a critical element in optimizing workflow efficiency. This webinar marks the beginning of our three-part “Essentials of Automation” series. This first webinar is designed to equip you with the knowledge and skills to utilize parameters effectively: enhancing the flexibility, maintainability, and user control of your FME projects.
Here’s what you’ll gain:
- Essentials of FME Parameters: Understand the pivotal role of parameters, including Reader/Writer, Transformer, User, and FME Flow categories. Discover how they are the key to unlocking automation and optimization within your workflows.
- Practical Applications in FME Form: Delve into key user parameter types including choice, connections, and file URLs. Allow users to control how a workflow runs, making your workflows more reusable. Learn to import values and deliver the best user experience for your workflows while enhancing accuracy.
- Optimization Strategies in FME Flow: Explore the creation and strategic deployment of parameters in FME Flow, including the use of deployment and geometry parameters, to maximize workflow efficiency.
- Pro Tips for Success: Gain insights on parameterizing connections and leveraging new features like Conditional Visibility for clarity and simplicity.
We’ll wrap up with a glimpse into future webinars, followed by a Q&A session to address your specific questions surrounding this topic.
Don’t miss this opportunity to elevate your FME expertise and drive your projects to new heights of efficiency.
PHP Frameworks: I want to break free (IPC Berlin 2024)Ralf Eggert
In this presentation, we examine the challenges and limitations of relying too heavily on PHP frameworks in web development. We discuss the history of PHP and its frameworks to understand how this dependence has evolved. The focus will be on providing concrete tips and strategies to reduce reliance on these frameworks, based on real-world examples and practical considerations. The goal is to equip developers with the skills and knowledge to create more flexible and future-proof web applications. We'll explore the importance of maintaining autonomy in a rapidly changing tech landscape and how to make informed decisions in PHP development.
This talk is aimed at encouraging a more independent approach to using PHP frameworks, moving towards a more flexible and future-proof approach to PHP development.
Kubernetes & AI - Beauty and the Beast !?! @KCD Istanbul 2024Tobias Schneck
As AI technology is pushing into IT I was wondering myself, as an “infrastructure container kubernetes guy”, how get this fancy AI technology get managed from an infrastructure operational view? Is it possible to apply our lovely cloud native principals as well? What benefit’s both technologies could bring to each other?
Let me take this questions and provide you a short journey through existing deployment models and use cases for AI software. On practical examples, we discuss what cloud/on-premise strategy we may need for applying it to our own infrastructure to get it to work from an enterprise perspective. I want to give an overview about infrastructure requirements and technologies, what could be beneficial or limiting your AI use cases in an enterprise environment. An interactive Demo will give you some insides, what approaches I got already working for real.
Software Delivery At the Speed of AI: Inflectra Invests In AI-Powered QualityInflectra
In this insightful webinar, Inflectra explores how artificial intelligence (AI) is transforming software development and testing. Discover how AI-powered tools are revolutionizing every stage of the software development lifecycle (SDLC), from design and prototyping to testing, deployment, and monitoring.
Learn about:
• The Future of Testing: How AI is shifting testing towards verification, analysis, and higher-level skills, while reducing repetitive tasks.
• Test Automation: How AI-powered test case generation, optimization, and self-healing tests are making testing more efficient and effective.
• Visual Testing: Explore the emerging capabilities of AI in visual testing and how it's set to revolutionize UI verification.
• Inflectra's AI Solutions: See demonstrations of Inflectra's cutting-edge AI tools like the ChatGPT plugin and Azure Open AI platform, designed to streamline your testing process.
Whether you're a developer, tester, or QA professional, this webinar will give you valuable insights into how AI is shaping the future of software delivery.
JMeter webinar - integration with InfluxDB and GrafanaRTTS
Watch this recorded webinar about real-time monitoring of application performance. See how to integrate Apache JMeter, the open-source leader in performance testing, with InfluxDB, the open-source time-series database, and Grafana, the open-source analytics and visualization application.
In this webinar, we will review the benefits of leveraging InfluxDB and Grafana when executing load tests and demonstrate how these tools are used to visualize performance metrics.
Length: 30 minutes
Session Overview
-------------------------------------------
During this webinar, we will cover the following topics while demonstrating the integrations of JMeter, InfluxDB and Grafana:
- What out-of-the-box solutions are available for real-time monitoring JMeter tests?
- What are the benefits of integrating InfluxDB and Grafana into the load testing stack?
- Which features are provided by Grafana?
- Demonstration of InfluxDB and Grafana using a practice web application
To view the webinar recording, go to:
https://www.rttsweb.com/jmeter-integration-webinar
JMeter webinar - integration with InfluxDB and Grafana
2011 Estate and Tennessee Update
1. A Global Reach with a Local Perspective
www.decosimo.com
2011 Estate and Tennessee Update
Chattanooga Chapter IMA
January 25th, 2012
Kim Lawrence
2. What’s New for Estate’s in 2011:
• Unified Estate, Gift, and Generation-Skipping
Transfer Tax
– Estate exemption at death is reduced by amounts
exempted for gifts during life
• Able to use full $5 million exemption to make lifetime
gifts without federal gift tax
• Tennessee still has gift tax and no lifetime exemption
3. Rates for 2011:
• Rates for estate and gift tax top out at 35%
• Exemption is set at $5 million
– Increases to $5.12 in 2012 to account for inflation
• TN annual exclusion remains $13,000 for
Class A, $3,000 for Class B
– Direct payments for tuition or medical expenses exempt from
threshold, 529 plan contribution 5 year election for $65,000
– Class A donees are immediate family members, siblings, lineal
descendants/ancestors, in-laws, step-children and in some cases
nieces and nephews. Class B donees are all other persons
– TN does recognize 529 plan contributions as completed gifts
4. Changes Extended from
2010 Tax Relief Act
• Portability for federal estate tax exemption
between spouses
– Death of the spouse must occur in 2011 or 2012
– Married couples able to pass $10 million to heirs tax free from
federal
• Ex: If husband dies and has used $2 million of his exemption,
then wife has $8 million available for exemptions on
remaining assets
– Must file an estate return electing to preserve the portability in
order to take advantage
– Note: Portability has NOT been adopted by state estate tax
exemption or Generation Skipping Transfer tax
5. Tennessee Estate Issues 2011:
• Tennessee Inheritance exemption remains
at $1 million
• Due 9 months after decedent’s death – extension of
up to one year
• Rate of up to 9.5%
• Does NOT recognize portability
6. Changes in Rates from 2010-2011
Tennessee
2011 2012 2013+ 2011+
Estate/Inheritance Tax
Exemption $5,000,000 $5,120,000* $1,000,000 $1,000,000
Maximum Estate Tax Rate 35% 35% 55% 9.50%
Gift Tax Annual Exclusion $13,000 $13,000 $13,000 $ 13,000 (Class A)
Per Donee $ 3,000 (Class B)
Lifetime Gift Tax Exemption $5,000,000 $5,000,000 $1,000,000 None
Maximum Gift Tax Rate 35% 35% 55% 9.5%
Exemption from Generation $5,000,000 $5,000,000 $1,000,000 TN GST equals Federal
Skipping Tax state GST tax credit
Generation Skipping Tax 35% 35% 55% TN GST equals Federal
Rate state GST tax credit
* Inflation adjustment
7. Case and MemorandumAICPA
• Gallagher v. Commissioner T.C. Memo 2011-148
Favorable-
– Fair market value of a minority interest in a closely held
business held in an estate was less the value determined
by the IRS and what the taxpayer reported
• Estate of Turner v. Commission-Unfavorable
– Decedent exercised a great amount of control as sole
general partner
• AICPA Suggestions for making permanent estate tax
and GST tax provisions
9. Legislative Highlights-
• HALL INCOME TAX-
– Effective 1/1/12- increases tax exemption for taxpayers older than 65
to $27,000 for single and $37,000 for married filing jointly taxpayers
• APPORTIONMENT-
– Effective 06/10/11- Goodwill required to be included as a Class VII
asset under Code Section 338(b)(5) and Section 1060 is excluded from
both the numerator and denominator of the apportionment formula
9
10. Legislative Highlights-
• EXCISE TAX-
– Effective tax years ended after 6/10/11-Excess rent paid
or accrued to an affiliate for the use of industrial or
commercial property is subtracted from the excise net
earnings to the extent it has been added to the net
earnings of the affiliate
10
11. Legislative Highlights
• Franchise Tax
– Brownfield Property Credit: equal to 50% of the purchase
price of Brownfield property purchased in Tennessee
during the tax period covered by the return for the
purpose of a qualified development project.
– Go Green! Machinery and equipment used to produce
electricity in a certified green production facility is not
treated as property actually used by the taxpayer in the
conduct of its principal business, for franchise tax
purposes.
11
12. Legislative Highlights-
• Job Tax Credit and Additional Job Tax Credits
– Credit applies when capital investment and job creation
requirements are met
– Allows the Commissioner to lower the job threshold 50 vs.
100 new jobs (amount of credit reduced proportionally)
– If the job threshold is reduced the credit is reduced
– Clarifies that the tier 2 and tier 3 credit and the capital
investment and job creation credit cannot both be taken
simultaneously
12
13. Legislative Highlights-
• Headquarter Relocation Credit
– Now allows credit for remodeled or expanded
headquarters facilities already located in TN
– Allows the Commissioner to lower the job threshold
requirement
– Applies to the sales tax credit as well
– Recapture:
• Changed the period that the taxpayer uses the facility to be
measured from end of investment period rather than substantial
completion
14. Legislative Highlights-
• Refund Periods May Be Extended
– Prior law: must be filed within one year
– Amended: may be extend the one year period by
agreement between Commissioner and taxpayer
• Expedited Letter Rulings
– Allows taxpayer the option of requesting “expedited” letter
rulings
– Fee shall not exceed $10,000
– Ruling will be issued within 60 days of the request date or
• Deny request and return the fee within 7 days after the submission
15. Legislative Highlights-
• Headquarters Sales Tax Credit
– Prior law:
• Only initial establishment of a headquarters facility
– Amended law:
• Now available to remodeled and expanded facilities
• Amended definitions for:
– Qualified expenditures
– Qualified Headquarter Facility- minimum capital investment of
$10 million and 100 new full-time jobs (net increase)
– Full-time Employee Job- must pay 150% of Tennessee’s average
occupational wage
16. Legislative Highlights-
• Sales Tax Disaster Assistance Refund-FEMA recipients
– TN Disaster occurred between 3-23-11 through 5-12-11
– Entitled to a refund of sales tax paid on eligible items
– Purchased between 03/23/2011, and 12/31/2011
– Sales and use tax paid on supplies used in a primary
residence
– Sales price not exceeding $3,200 per item for appliances
and furniture
– Sales price not exceeding $500 per item for residential
building supplies
– Maximum refund per residence: $2,500
– Must file application by February 29, 2012
17. Legislative Highlights-
• Credit and NOL Carryforward Amendments
– Prior law: Allowed waiver of the 15-year carry forward
limitation for capital investments in excess of $1 billion
with Commissioner approval
– Amended: Waiver power has been eliminated
18. Legislative Highlights-
• Personal Property Tax Filing Requirements
– Prior Law:
• County assessor required to furnish with schedule by
February 1 each year showing valuation of tangible
personal property in prior years.
– Amended Law:
• Failure of the assessor to send a schedule or failure of
the taxpayer to receive a schedule shall not relieve or
excuse any taxpayer from filing requirements by March
1 nor shall it prevent the assessor from issuing a forced
assessment against the taxpayer
• Limits on reasons as to why returns can be amended
19. Case Update-
• Blue Bell Creameries, L.P. v. Roberts, (2011)
– TN Supreme Court reverses unitary business decision
– Stock redemption gain subject to tax on apportioned basis rather than
as nonbusiness earnings
– Court reinstated that
• Earnings qualify as business earnings if they satisfy the transactional or
functional test
• Unitary business determination under the Operational-Function test:
– If asset helps taxpayer make better use of the existing business-
related resources, it serves an operational function and is part of
unitary business
– If asset serves to diversify a taxpayer and reduces risk of being tied to
one business, it serves as an investment function as is not part of
unitary business
20. Case Update-
• COA Holdings, Inc. v. Trost
– Prior Situation
• Cross-motion for Summary Judgment: allowed parties
to reach efficient resolutions without the time/expense
of a trial
– Result: Only be granted when material facts are not in
dispute and when only one conclusion or inference can
reasonably be drawn from the facts
• More difficult to request summary judgment and be
forced to try a case
21. Case Update-
• Valenti Mid-South Management, LLC v. Farr
– “Affiliated Group” - may elect to compute net worth on a consolidated
basis
– Result:
• Not affiliated group, no basis for double taxation
– Open Questions:
• Affiliated group can calculate franchise tax based on consolidated property
value or consolidated net worth
• How to calculate the value of property that is leased from one member of
the affiliated group to the other
22. 2010-2011 Letter Rulings
• Code Section 754 Election-Ruling 11-78
– Results in step-up in basis for TN excise tax purpose (limited
circumstances)
• Sales & Use Tax Applicable to Hostess Discounts-Ruling 11-00
– Hostess purchased products using discount
• Payment for discount was part of total consideration paid for by
the hostess
– Sample Products: based on amount paid by the advisor
• Original price less the value of award product certificate
23. Bills of Interest – Not Passed
• Combined Reporting Bill
– Would have required combined reporting for unitary businesses
• Amazon.com Click-Through Nexus
– Out of state internet retailers would be subject to sales tax if they
receive potential customer referrals from TN residents (i.e. link on
website) and
– Retailer cumulative gross receipts through referrals exceed $4,800 for
four consecutive quarterly periods
• Discriminatory Taxes on Digital Goods and Services
– Would have prohibited state from imposing multiple or discriminatory
taxes on digital goods or digital services